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- A key challenge is found in the lack of semantic harmonization for personal data control which provides security for the portability of private information is required upfrontas a precondition to data control and portability.
- to address this issue a unified notice control language which can be used to address harmonisation of the notice to indicate which Data Subjects rights apply to which context, and which data controls are authorized to be used by the Data Subject.
- whats involved
- use/finish the latest Operational Notice & Consent Receipt Specification -Kantara V1.2 that combines the ISO 29100 & 29184 and 27560 -standards comprised of the International privacy security framework (for Soverign data transfer)
- start a generic - unified data control notice schema - mapped to the ISO 29100 framework -
- map/generate legal overlays for this core overlay to Create an OCA test schema framework. a single international baseline overlay - ANCR WG- ISO 27560 - Notice & Consent Receipt - Record Structure.
Key Points to consider:
sovereign identity, a data processing activity is based on a data subject’s explicit or otherwise (human) consent (not internet service /cookie consent),
an individual’s privacy rights need to be extended to proportional digital privacy rights, so an overlay extends the analogue privacy law with a standard digital control semantics with the unified data control. This requires a legal (computational law) use case to illustrate (action for Mark Lizar
Digital Rights usage Challenge
different legal justifications have different rights associated with them. This makes it very difficult for people and orgs to know what rights apply in any given data control context - a problem that the can be solved with the use of these standards -
e.g. a notice for explicit consent - or legitimate interest? when does a Data subjects have the right to data portability (Article 20) when is processing is based on consent. When not used on consent- people have the right to object (Article 21)
the right to withdraw consent may provide a different outcomes - -
Articles 16 to 20 of the GDPR indicate that (when data processing is based on consent), data subjects have the right to erasure when consent has been withdrawn and the rights to restriction, rectification and access.
- Gaps to cover
- core schema base
- what missing in this base?
- Verified Privacy Controller Credential
Unified Notice Control Language for Semantic (inputs)
For UNCL - the aim is to start a specification with the key roles specified for data control, transparency and accountability as the starting point. And to start with the Privacy Controller, the key authorizing stakeholder for data processing, and to represent this in the. standards and references for legal governance, and to currate a list of proposed (new terms/elements to explore)
Requirements Privacy Controller Credential Specification
chain starts with the person who is accountability.
Legal Entity Accountability
Tier 0 - is self asserted controller (not a verified privacy controller) even in the ICO Controller Registry
Tier 1 - Privacy Controller - with low risk services - (employee privacy )
Tier 2 - High Risk Privacy
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- identity management, any specifically category of data -
Tier 3 - Very High Risk - Beneficial owners -
UNCL - starting with HTML tags ? for schema ?
Objective - is to have a single identifier for a Privacy Controller, which includes all LEI's for beneficial ownership.
- Privacy - Transparency over legal entities, accountable people and beneficial -
- Legal Entity Identifier
- to identify the legal entity of the privacy controller
- beneficial owner of the legal entity
- Accuntable Person
- to identify the accountable person / role that is bound to the legal entity identifier (aka) organization.
- could be an employee
- owner / director / officer
- data proaction officer
- 3rd. Party Company Representative
- accountable role - (for another 3rd Party) acting representative
- to identify the accountable person / role that is bound to the legal entity identifier (aka) organization.
- Privacy Controller
- under what authority
- under what legal justification
ISO 29100 Actors
(Note: In progress - consulting with Steven on auto filling)
Data Governance Authority / | |||
---|---|---|---|
Certification Providers on Regulator Approved Codes of Conduct - very limited PII - data controller personal information and a linked reference to a data subjects identifier - |
Privacy Stakeholders | ISO Definition | |
---|---|---|
Regulator / | ||
PII Principal | ||
PII Controller | ||
PII Processor | ||
3rd Party |
Roles for Credentials | Description | |
---|---|---|
Issuer | ||
Holder | ||
Verifier |
Gov ToiP Role | UseCase Example | Roles | Actors Privacy Stakeholders
| |
---|---|---|---|---|
Provides the schema - hospital | issuer | Privacy Controller | ||
Person - Requesting Information from - patient/traveller | holder | Data Subject | ||
3rd Party - border control | Verifier | Data Processor / 3rd Party |
- looking to make a process for what Legal Privacy Stakeholder has the Credential Role
- Steps to assign Stakeholder Roles
- Test for checking if its a processors or a 3rd party?
- Steps to assign Stakeholder Roles
Legal Semantic Element | semantic description | functional usage | fields Required | |
---|---|---|---|---|
controller | ||||
controller_identity | ||||
controller address registered | ||||
controller address (mailing) | ||||
controller contact | extend consent termination for a control point |
Delegated Role :
Delegated | |||
---|---|---|---|
Regulator | Ombudsman | ||
PII Principal | Guardian | ||
PII Controller | Joint-Controller | ||
PII Processor | Sub-Processor | ||
3rd Party | turtles |
References for use for creating a Unified (generic) Data Control Vocabulary for OCA
Standard/Specifications | Title | Description | Resource Status |
---|---|---|---|
ISO 29100 | Information technology — Security techniques — Privacy framework | ISO/IEC 29100:2011 provides a privacy framework which
| Status - Is publicly available - https://www.freestandardsdownload.com/iso-iec-29100-2011.html |
ISO/IEC 29184:2020 | Online privacy notice and consent | (just published - not available to public - we are working on publishing a report/appendix for use with this group ) | |
W3C DPV 0.01 | Data Privacy Vocabulary |
|
|
Topic List
Topic Title | ||
---|---|---|
Risks | ||
Mapping Governance | Matching with ToiP Governance | |
References
Topic | Link | |
---|---|---|
Risks | Identity and Verifiable Credential Risks | |
Reference Implementations
Implementer | |||
---|---|---|---|
Human Colossus | |||
OpenConsent | |||
I_Grant |
OPN: Open Notice (+ Consent) Receipt Schema: Starters Guide to Unified Data Control Schema
Lizar, M. & Pandit, H.J., OPN: Open Notice Receipt Schema, 14th International Conference on Semantic Systems (SEMANTiCS 2019), Karlsruhe, Germany, 2019 [Published http://www.tara.tcd.ie/handle/2262/91576 [accessed July 1, 2020]
Field Name | Field Label | Format | Description | Required/Optional |
Schema Version | version | string | Required | |
OPN Privacy Profile URI | profile | string | Link to the controller's profile in the OPN registry. | Required |
Type of Notice Receipt | Notice Receipt | string | Label Notice Receipt | Required |
Receipt ID | id | string | A unique number for each Notice Receipt. SHOULD use UUID-4 [RFC 4122]. | Required |
Timestamp | timestamp | integer | Date and time of when the notice was generated and provided. The JSON value MUST be expressed as the number of seconds since 1970-01-01 00:00:00 GMT (Unix epoch). | Required |
Signing Key | key | string | The Controller’s profile public key. Used to sign notice icons, receipts and policies for higher assurance. | Optional |
Language | language | string | Language in which the consent was obtained. MUST use ISO 639-1:2002 [ISO 639] if this field is used. Default is 'EN'. | Optional |
Controller Identity | controllerID | string | The identity (legal name) of the controller. | Required |
Legal Jurisdiction | jurisdiction | string | The jurisdiction(s) applicable to this notice | Required |
Controller Contact | controllerContact | string | Contact name of the Controller. Contact could be a telephone number or an email address or a twitter handle. | Required |
Link to Notice | notice | string | Link to the notice the receipt is for | Optional |
Link to Policy | policy | string | Link to the policies relevant to this notice e.g. privacy policy active at the time notice was provided | Required |
Context | context | string | Method of notice presentation, sign, website pop-up etc | Optional |
Receipt Type | The human understandable label for a record or receipt for data processing. This is used to extend the schema with profile for the type of legal processing - and is Used to identify data privacy rights and controls |
OCA schema specification: https://docs.google.com/spreadsheets/d/1KOdq8Yy3OXmuELyh7tpHMlhyMZPSZ3Ib/edit#gid=68769926
ISO 29100 Actors
(Note: In progress - consulting with Steven on auto filling)
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Privacy Stakeholders
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ISO Definition
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Gov ToiP Role
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Legal Receipt Type for action or event
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Actors
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Delegated Role :
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Delegated
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References for use for creating a Unified (generic) Data Control Vocabulary for OCA
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Standard/Specifications
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Title
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Description
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Resource Status
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Information technology — Security techniques — Privacy framework
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ISO/IEC 29100:2011 provides a privacy framework which
- specifies a common privacy terminology;
- defines the actors and their roles in processing personally identifiable information (PII);
- describes privacy safeguarding considerations; and
- provides references to known privacy principles for information technology.
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- legal ontology for technically breaking down and mapping legal ontology to a data legal ontology -
- the Notice + CR V1.2 and W3C DPV, also use a common set of purpose categories. and the Kantara CR v1.1 for purpose specification
- (note shared by initial FIHR approach - now much more evolved)
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- active -
- additional information
- Background: EU Funded Project Special
- Creating a Vocabulary
Topic List
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Topic Title
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References
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Topic
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Link
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Reference Implementations
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Implementer
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